One-page summary
July 28, 2026
The proposed BCBSM incident-to policy change, measured
A statewide survey of Michigan's behavioral health workforce and the people it serves, conducted June 17–30, 2026 by MMHCA, NASW-Michigan and MPA.
689
Limited licensed providers
1,856
Fully licensed & practice owners
224
Clients
4,634
Written responses
2,769
Total respondents statewide
What we are asking
We are not requesting a delay or further study. We are asking Blue Cross Blue Shield of Michigan to keep the current framework as the permanent policy for limited licensed clinicians in professional settings, and to open a direct credentialing pathway for them.
Five headline findings
01
Thousands of clients face immediate disruption
Respondents represent more than 5,700 BCBSM clients seen weekly by limited licensed providers. Over 1,000 are in active crisis stabilization or safety planning.
02
73% of clients would go without care
Only 3 of 224 client respondents said they could afford out-of-pocket care without financial difficulty.
03
The workforce pipeline faces structural disruption
68% of limited licensed respondents will not hold full licensure by March 1, 2027. 41% of practices have already paused limited licensed hiring.
04
Private practices cannot absorb the displaced clients
89% of fully licensed respondents report they could not take on additional clients. Responding practices estimate their fully licensed staff could absorb roughly 1 in 5 of the affected clients.
05
The impact is likely understated
The surveys reached current LARA licensees only. More than 2,500 newly licensed limited licensed counselors from last year's cohort appear nowhere in these figures.
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Two dates
September 1, 2026: incident-to claims must carry the SA modifier. March 1, 2027: limited licensed clinicians lose incident-to eligibility in professional practice settings.
Method. Three parallel surveys, June 17–30, 2026, sent by email to approximately 48,000 licensed Michigan behavioral health professionals across four association lists, and to clients through their providers. Participation was voluntary, so these are the experiences of those who chose to respond, not a random sample. That three independently surveyed populations converged at that rate is itself a finding.
Full report and action tools
mmhcanow.org/bcbsm-impact
MMHCA, NASW-Michigan & MPA. Statewide Policy Impact Assessment: Proposed BCBSM Incident-to Billing Policy Changes. July 28, 2026.